Skip to content
BOL Conferences
Thread Options
#2190749 - 08/27/18 08:53 PM DOJ contractors - supporting doc request
RFBanker Offline
Member
Joined: Jun 2006
Posts: 73
I recently received a request for supporting documentation on a SAR from a contractor working for the DOJ. Can anyone point me to some guidance or interpretation to document and verify they have proper authority to make the request? Their purported role is to identify credible leads for DOJ to pursue using data analytics.

They had the DCN and a DOJ email address which gives me some comfort that it is a legitimate request.

Return to Top
BSA/AML/CIP/OFAC Forum
#2190751 - 08/27/18 09:08 PM Re: DOJ contractors - supporting doc request RFBanker
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,351
New York City
I would think that this would qualify as a legitimate request but I would run it up to legal for their feedback prior to providing any information.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2190754 - 08/27/18 09:13 PM Re: DOJ contractors - supporting doc request RFBanker
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,400
Galveston, TX
Hmmm - I might go the other way on this. A contractor is not law enforcement. If the DOJ wants them to have this information then the DOJ should request it and give it to them. Let them worry about the confidentiality aspect.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2190755 - 08/27/18 09:16 PM Re: DOJ contractors - supporting doc request RFBanker
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
I'm with rlcarey. Would insist the DOJ request.

Return to Top
#2190853 - 08/28/18 04:24 PM Re: DOJ contractors - supporting doc request RFBanker
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Ditto the two above.

Return to Top
#2190955 - 08/28/18 10:02 PM Re: DOJ contractors - supporting doc request RFBanker
RFBanker Offline
Member
Joined: Jun 2006
Posts: 73
Thanks for your input. If interested, our counsel provided a response. However, please consider as FYI and not legal advice that I myself am not qualified to give:

The request should come directly from an employee of the DOJ, and then if the DOJ chooses, it can share that information with the contractor. So, we recommend pursuing one of the following avenues:

Have the request come directly from a DOJ employee, and send the supporting documentation directly to the DOJ. If the DOJ then chooses to share the information with the contractor, it is out of the Bank's hands. Or,

Have the DOJ request and authorize the Bank in writing to provide the supporting documentation directly to the contractor. To be safe, the DOJ should likely be copied on any materials sent to the contractor in accordance with that request.

Return to Top

Moderator:  Andy_Z